Section 22 of the National Prohibition Act provides that premises used for purposes in violation of the act, such as the sale of intoxicating liquor, may be declared a common nuisance which may be enjoined in equity, and that the premises may be closed for one year. Process was served on the defendant who was the bartender in a "speakeasy," and the place was declared a common nuisance and padlocked for one year. The lessee of the premises, who was the proprietor of the business, appeared specially to vacate that part of the decree which directed the closing of the premises. Held, that since the suit was one in personam, it was necessary to serve the lessee personally as a party defendant in order to bind his interest in the premises by the decree, and the order closing the premises was vacated. United States v. Fox, (C. C. A. 2d, 1932) 60 F. (2d) 685.